Marshall v O'Flaherty (Costs)

Case [2023] NSWDC 61


District Court


New South Wales

  • Amendment notes
Medium Neutral Citation: Marshall v O'Flaherty (Costs) [2023] NSWDC 61
Hearing dates: 16 March 2023
Date of orders: 17 March 2023
Decision date: 17 March 2023
Jurisdiction:Civil
Before: Gibson DCJ
Decision:

(1)   Defendant’s application to set aside order (3) of the orders made by Taylor SC DCJ on 25 October 2022 is dismissed.

(2)   The costs of this application are to be included in the costs order of 25 October 2022 when these costs come to be agreed or assessed.

Catchwords:

COSTS – plaintiff brings applications for leave to commence proceedings in the District Court of NSW pursuant to s 26(3) of the Personal Injury Commission Act 2020 (NSW) and to commence proceedings out of time pursuant to s 109 of the Motor Accident Compensation Act 1999 (NSW) – applications granted – orders for costs to be costs in the proceedings but with liberty to apply – defendant seeks orders that the plaintiff pay the defendant’s costs – the “indulgence principle” – role of any “indulgence” factors in the exercise of the court’s discretion – relevance of combative opposition to the orders sought by the plaintiff – degree of weight to be given to orders proposed by the judge hearing the application, who had the benefit of written submissions on costs – whether any new or different costs factor identified – application to vary costs order dismissed.

Legislation Cited:

Motor Accident Compensation Act 1999 (NSW), s 109

Personal Injury Commission Act 2020 (NSW), s 26

Workers Compensation Act 1987 (NSW), s 151D

Cases Cited:

Brimaud v Honeysett Instant Print Pty Ltd (1988) 217 ALR 44

Choukor v Spiroski (No 2) [2017] NSWDC 15

Fordham v Fordyce [2007] NSWCA 129

Franco v Workers Compensation Nominal Insurer [2020] NSWSC 915

Halikos Hospitality Pty Ltd & Ors v Inpex Operations Australia Pty Ltd [2017] NTSC 17

Holt v Wynter (2000) 49 NSWLR 128; [2000] NSWCA 143

Judd v Warwick (Costs) [2007] NSWDC 300

Muriniti v Kalil [2022] NSWCA 109

Rafiqi Islam v Transport Accident Commission of Victoria and Heather Worldon v Transport Accident Commission of Victoria [2022] NSWDC 582

Seary v White (No 5 - Costs) [2008] NSWDC 21

Smith v Grant (2006) 67 NSWLR 735

Stanley v Layne Christensen Company [2006] WASCA 56

Stein v Ryden [2022] NSWCA 212

The President’s Club Limited & Anor v Palmer Coolum Resort Pty Ltd & Anor (No 2) [2020] QSC 11

Wang v ABC Homes (NSW) Pty Ltd (No 2) [2018] NSWSC 1736

Texts Cited:

Nil

Category:Costs
Parties: Phillip Kenneth Marshall (plaintiff)
Thomas O'Flaherty (defendant)
Representation:

Counsel:
Mr B Kelleher SC (plaintiff)
Mr B Jones (plaintiff)

Mr J Turnbull SC (defendant)

Solicitors:
Stacks Goudkamp (plaintiff)
Carroll & O'Dea Lawyers (defendant)
File Number(s): 2021/00350695
Publication restriction: Nil

Judgment

Introduction

  1. The plaintiff was involved in a motor vehicle accident on 3 March 2016. The relevant insurer, the Transport Accident Commission (“TAC”) admitted liability for the accident. The plaintiff also required leave to proceed out of time.…

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Details
AGLC
Marshall v O'Flaherty (Costs) [2023] NSWDC 61
Case
[2023] NSWDC 61
Decision Date

CaseChat Overview and Summary

The case of Marshall v O'Flaherty involved the plaintiff, Marshall, who had brought applications for leave to commence proceedings in the District Court of New South Wales under the Personal Injury Commission Act 2020 (NSW) and to commence proceedings out of time under the Motor Accident Compensation Act 1999 (NSW). Both applications were granted, and orders for costs were made, allowing for the costs to be costs in the proceedings but with liberty to apply. Subsequently, the defendant, O'Flaherty, sought orders that Marshall pay O'Flaherty’s costs, raising questions about the indulgence principle and the appropriate weight to give to orders proposed by the judge.

The legal issues in the case centred on the exercise of the court's discretion in awarding costs, particularly the application of the indulgence principle. The court was required to consider the role of any indulgence factors in the exercise of its discretion, the relevance of combative opposition to the orders sought by the plaintiff, and the weight to be given to the orders proposed by the judge, who had the benefit of written submissions on costs. Additionally, the court had to determine whether any new or different costs factors had been identified that warranted a variation of the original costs order.

In addressing these issues, the court noted that the indulgence principle required a consideration of all relevant factors, including the combative nature of the opposition. However, the court found no new or different costs factors that warranted a variation of the original costs order. The court further held that the orders proposed by the judge, who had the benefit of written submissions, should be given appropriate weight. The application to vary the costs order was dismissed, and it was ordered that the costs of the defendant’s application be included in the costs order of 25 October 2022 when these costs come to be agreed or assessed.

Orders

Orders of the court

(1) Defendant’s application to set aside order (3) of the orders made by Taylor SC DCJ on 25 October 2022 is dismissed.

(2) The costs of this application are to be included in the costs order of 25 October 2022 when these costs come to be agreed or assessed.

Background

Background to the litigation

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Evidence

Evidence Before The Court

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Decision

Reasons for decision

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Ratio Decidendi

Legal Principle Established

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